On Thursday, February 27, 2014, the DEA issued a long-awaited Notice of Proposed Rulemaking (NPRM) seeking to reschedule hydrocodone combination products as Schedule II controlled substances. In a previous post we questioned whether such a step would actually have an impact on the abuse and diversion of these drugs. DEA relied on the scientific analysis of the Department of Health and Human Services and the DEA’s own eight-factor analysis to conclude that substantial evidence of the high potential of abuse for hydrocodone combination products exists to support the placement of these types of drugs in Schedule II.

The NPRM allows public comments on the proposed rule. Moreover, interested parties may seek a hearing before the DEA to contest the proposed rulemaking action. Comments should be received by the DEA by April 27, 2014. Requests for hearing are due no later than March 31, 2014.

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